Turco v. Commissioner
United States Tax Court
Petitioners leased property to the California Highway Patrol under a 10-year lease beginning in January 1963. Later in that year problems with the septic tank used for the property developed which petitioners sought to remedy in various ways. Petitioners sold the property, subject to the lease, in June 1964. Soon thereafter there was a recurrence of the septic tank trouble and petitioners voluntarily took over the problem.
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Petitioners leased property to the California Highway Patrol under a 10-year lease beginning in January 1963. Later in that year problems with the septic tank used for the property developed which petitioners sought to remedy in various ways. Petitioners sold the property, subject to the lease, in June 1964. Soon thereafter there was a recurrence of the septic tank trouble and petitioners voluntarily took over the problem. In 1965 petitioners paid $ 7,281.26 in connection with the installation of a connecting sewer pipe from the property to the municipal sewage system. Held: The expenditures…
1Opinion of the Court
OPINION
Petitioners argue that they undertook in 1965 to correct the septic tank problems on the Vallejo property sold by them in 1964 for the purpose of fostering the goodwill of the Highway Patrol; that the expenditures incurred were in furtherance of their business of leasing property; and that consequently they are entitled to deduct such amounts as ordinary and necessary business expenses under section 162, I.R.C. 1954.1 Bespondent contends that the expenditures incurred in 1965 were not ordinary and necessary expenses of petitioners’ business, but were directly related to the sale of the…
2Cases cited6 opinions
- Arrowsmith v. CommissionerSupreme Court of the United States · 1952
- Lowe v. CommissionerUnited States Tax Court · 1965
- Mitchell v. CommissionerUnited States Tax Court · 1969
- Rees Blow Pipe Mfg. Co. v. CommissionerUnited States Tax Court · 1964
- Rees Blow Pipe Manufacturing Company v. Commissioner of Internal Revenue, Commissioner of Internal Revenue v. Rees Blow Pipe Manufacturing CompanyCourt of Appeals for the Ninth Circuit · 1965
1 more not listed; retrieve them via the Exa API.
3Cited by10 opinions
- Bresler v. CommissionerUnited States Tax Court · 1975
- Anderson v. CommissionerUnited States Tax Court · 1971
- Federal Bulk Carriers, Inc. v. CommissionerUnited States Tax Court · 1976
- Nelson v. CommissionerUnited States Tax Court · 1971
- Slater v. CommissionerUnited States Tax Court · 1975
5 more not listed; retrieve them via the Exa API.